Plans by some states to force adoption of wind, solar, and other renewable energy technologies — to the exclusion of coal — may face legal roadblocks from surrounding states. Legislatures in states that include Oregon, Colorado, and Minnesota have adopted statutes restricting or completely prohibiting the importation of electrical power generated by coal-fired plants. Such measure have started litigation battles with neighboring, coal-rich states, such as South Dakota, which complain that the measures are unconstitutional. They argue that these novel statutes violate the Constitution’s Dormant Commerce Clause because of their extra-territorial effect. Both the Eighth and Ninth Circuits are currently considering the issue.